Growth and Infrastructure Bill

Memorandum submitted by Deloitte on behalf of the BST Group (GIB 17)

Clause 21: Bringing Business and Commercial Projects within the Planning Act 2008

1. This evidence is submitted by Deloitte on behalf of the BST Group who is a major landowner and investor responsible for delivering a substantial part of a new community in Hampshire which will provide in the order of 6,000 homes, employment floor space to support 4,000 jobs, primary and secondary education and community facilities. All of which will be served by a bus rapid transit system.

2. This project is typical of the large scale sustainable developments that are envisaged by the National Planning Policy Framework (NPPF), and have a key role to play in creating growth in the economy, and meeting the acute need for private and affordable housing.

3. The NPPF published in March this year, reinforced by the statements on housing and growth made by the Prime Minister and the Secretary of State for the Department of Communities and Local Government on the 6 September underlined the vital importance of accelerating the delivery of new housing and employment developments. This is a key plank of the Government’s economic and planning policy.

4. These developments should be planned following the principles of garden cities and should have locally based support.

5. The proposed new community to the north of Fareham is a high priority of the PUSH local authorities, and is being led by Fareham Borough Council. It is in the adopted Fareham Core Strategy and the PUSH Strategy for South Hampshire. It therefore falls into the category of a major growth project which is supported locally.

6. Projects such as this will often require improvements to the strategic highway network and other infrastructure which is likely to require Development Consent Orders under the Planning Act (2008).

7. Clause 21 of the Growth & Infrastructure Bill enables the Secretary of State to direct that business and commercial projects of national significance can be considered under the nationally significant infrastructure regime contained in the Planning Act 2008. However, dwellings are excluded.

8. The inclusion of business and commercial projects within the Development Consent Order is welcome. It enables the benefits of a single consent regime working to a rigorous timetable to be extended to the business element of major projects requiring infrastructure improvements.

9. However, the exclusion of dwellings is a serious missed opportunity, and flaw in the proposal.

10. It is well accepted that sustainable development of large scale projects will usually require a mixed use approach, where new employment generating development is located alongside new housing. This is a fundamental principle of sustainable development and garden cities, and usually very important to the viability and funding of these projects.

11. Moreover, the Government’s Housing Strategy, NPPF and Statements on the 6 September this year all recognise the fundamental importance to the growth of the economy of a strong housing sector, and the role of house building in creating economic growth.

12. Excluding dwellings from Clause 21 will therefore be contrary to the principle of sustainable development, and for large scale mixed use projects requiring Development Consent Orders will impose the need for separate applications for planning permission for the housing elements of major schemes to be run in parallel with the development consent order process.

13. This will create huge additional costs for developers and local authorities, substantially increase the complexity and risk profile of delivering new garden cities or sustainable communities because two separate processes will have to be run in parallel or even worse in sequence. This will further delay the delivery of much needed new homes.

14. We request that the committee recommends to government that dwellings should be incorporated into the definition of Clause 21.

15. We would be happy to provide further information or to answer further questions that the committee may have.

November 2012

Prepared 21st November 2012